Wednesday, May 29

6:00 – 8:00 PM | Opening Reception Hosted by Crowe LLP
Penn Avenue Terrace (JW Marriott Lobby)

Thursday, May 30 

8:00 – 9:00 AM | Registration + Breakfast

9:00 – 10:00 AM | 1) Tax Legislative Outlook
Senior staff from the U.S. House of Representatives Committee on Ways and Means, the U.S. Senate Committee on Finance and the Joint Committee on Taxation will provide their perspectives on the current and future tax legislative agenda, including the potential for enactment of tax legislation for the remainder of the year and the potential impact of the pending Presidential and Congressional elections.

Moderator: Marc Gerson, Member, Miller & Chevalier
Jonathan Goldman, Senior Tax Counsel, U.S. Senate Committee on Finance, Democratic Staff
Andrew Grossman, Chief Tax Counsel, U.S. House of Representatives Committee on Ways and Means, Democratic Staff
Kate Lindsey, Tax Policy Advisor, U.S. Senate Committee on Finance, Ranking Member Crapo
Cecily Rock, Senior Legislation Counsel, Joint Committee on Taxation 
Derek Theurer, Chief Tax Counsel, U.S. House of Representatives Committee on Ways and Means, Republican Staff 

10:10 – 11:10 AM | Concurrent Tracks

2A) International Tax Issues of Importance to the Insurance Industry- Inbound

This panel will discuss international tax developments impacting inbound insurance groups including US trade or business and permanent establishment issues in light of the recent YA Global case and the latest guidance on the excise tax on stock buybacks from an inbound perspective. The panel will also cover the Bermuda Corporate Income Tax (CIT) and its interaction with OECD Pillar 2 with examples, and the BEPS MLI in general.

After completing this course, you will be able to:

  • Understand how Bermuda CIT and Pillar Two might impact a foreign-parented multinational group.
  • Apply the modified CAMT applicable corporation test to a foreign-parented multinational group.
  • Obtain a general appreciation of recent changes to US double tax treaties and the impact of MLIs.
  • Appreciate the impact of the YA Global case on US trade or business issues.

Moderator: Surjya Mitra, Managing Director, PwC
John Owsley, Senior Manager, International Tax and Transaction Services, Ernst & Young LLP
Ezriel Strum, Tax Senior Manager, Deloitte Tax LLP
Joseph W. Tedesco, Jr., SVP & Global Head of Tax, AXA XL

2B) Life Insurance Company Tax Items of Interest
The panel will discuss company taxation issues that are top of mind for life and annuity providers.  Topics to be discussed include panelists’ initial thoughts on guidance related to the Corporate Alternative Minimum Tax (CAMT) and its impact on the insurance industry – including recent IRS/Treasury guidance.  The panel will explore recent technical developments in the area of life and annuity tax reserving.  Hot topics in accounting and reporting will be presented, including impacts of the current economic and interest rate environment on investment portfolios and their related impacts on other comprehensive income, valuation allowance, etc.

After completing this course, you will be able to:

  • Understand implications of recent life insurance company technical developments and guidance.
  • Interpret and understand guidance and technical developments related to life and annuity reserving.
  • Identify items from the IRS Priority Guidance Plan as they relate to life and annuity insurance providers.

Moderator: Matthew Lodes, Partner, PwC
Graham Cahill, Lead Counsel, Massachusetts Mutual Life Insurance Company
Jacob Hart, VP Financial Reporting and Tax, Unum Group
Kathryn M. Sneade, Branch Chief, IRS Office of Chief Counsel (FIP)
Joseph Vaccaro, Principal, KPMG LLP

2C) How Did We Get Here?: The History of Insurance Taxation in 60 Minutes or Less
The panel will provide a high-level history of the taxation of life insurance and property and casualty insurance companies.  The panel will discuss the evolution of the taxation of insurance companies with an eye to understanding how we got to where we are today.

After completing this course, you will be able to:

  • Have a basic understanding of the origins and history of taxation of insurance companies.
  • Understand some of the key factors that influenced the changes to insurance taxation.
  • Have a deeper understanding of how the current rules governing insurance taxation evolved.

Moderator: Kristan Rizzolo, Senior Counsel, Eversheds Sutherland
Jason Divine, Managing Director, Business Tax Services, KPMG LLP
Sanjeev Doss, Attorney At Law
Peter H. Winslow, Partner, Scribner, Hall & Thompson LLP

11:10 – 11:30 AM | Morning Break

11:30 AM – 12:30 PM | Concurrent Tracks

3A) International Tax Issues of Importance to the Insurance Industry- Outbound
This panel will discuss international tax developments impacting outbound insurance groups. A case study format will be used to illustrate the multi-dimensional analysis required of today’s tax practitioner in a new international tax landscape which includes Pillar 2 and Bermuda Corporate Income Tax (CIT).  Topics to be discussed include the recent proposed foreign currency regulations, the corporate alternative minimum tax (CAMT) rules, the interplay of the controlled foreign corporation (CFC) and passive foreign investment company (PFIC) regimes; the Bermuda CIT impact on 953(d) companies, Foreign Tax Credits, CFC’s, Pillar 2; Tax Accounting, adjustments to stock basis in acquired CFCs, and the status of public country-by-country (CBC) reporting rules.

After completing this course, you will be able to:

  • Recognize the complex and multidimensional analysis necessary to understand the international tax environment today.
  • Understand a variety of international tax issues that impact outbound structures.
  • Better apply a case study approach to outbound structure analysis.

Moderator: Stephen Baker, Managing Director, Washington National Tax, Deloitte Tax LLP
Paul Aronoff, Vice President, Prudential Financial Inc.
Paul Crispino, Attorney Advisor, (International Tax Counsel), Office of Tax Policy, U.S. Department of the Treasury
Chris Ocasal, Principal, Ernst & Young LLP
Douglas Poms, Principal, KPMG LLP
Christopher Riffle, Principal, PwC

3B) Corporate Alternative Minimum Tax (CAMT): Industry Issues
The panel will discuss the CAMT and its impact on insurers.  Topics to be discussed include interim guidance released over the last year, areas in which guidance has not been received, and where additional clarifications and questions have come up in relation to the interim guidance that may be addressed in proposed regulations.  The panel will explore relevant topics such as, but not limited to, partnership distributive share of Adjusted Financial Statement Income (AFSI); how to interpret the duplication/omission guidance specifically with respect to LDTI and IFRS 17 adoptions; and intercompany tax allocations and the accounting under SSAP 101.  A government speaker will be included in the panel to answer questions on these and similar topics important to the insurance industry.

After completing this course, you will be able to:

  • Identify the impact of recent IRS/Treasury guidance on the CAMT to the insurance industry
  • Differentiate areas where guidance has been issued vs areas for which guidance on CAMT is still needed
  • Apply the guidance issued under the interim guidance to specific insurance company fact patterns

Moderator: Carl Barkson, Managing Director, Ernst & Young LLP
Lauren Allen, Senior Tax Manager, Deloitte Tax LLP
Pamela Biesecker, Senior Vice President, Head of Tax, Nationwide Mutual Insurance Company
Daniel Phillips, Senior Counsel, IRS Office of Chief Counsel (FIP)
Mark Smith, Managing Director, PwC
Angela Walitt, Attorney Advisor, Office of Tax Policy, U.S. Department of the Treasury

3C) InsurTech – Developing Industry Trends and Tax Topics
The panel will provide an overview of the latest landscape in the InsurTech space and market participants. Topics will include various Insurtech structures, including MGA/MGUs, Captives, RRGs and Reciprocals. The panel will also address tax technical topics that the industry may be facing at various stages of growth and development. Additionally, the panel will discuss market development and future trends based on current market conditions.

After completing this course, you will be able to:

  • Address and discuss general trends and developments in the InsurTech market.
  • Provide an overview of key topics raised in conversations involving InsurTechs and other market participants.
  • Discuss and consider various Insurtech structures, including MGA/MGUs, Captives, RRGs and Reciprocals among others.
  • Address tax technical topics that may be facing InsurTechs at various stages of growth and development.

Moderator: Adgar Sarian, Director, PwC
Janine Burman-Gage, Senior Manager, Ernst & Young LLP
Matthew Jones, Partner, KPMG LLP
Juan Ortiz, Tax Senior Manager, Deloitte Tax LLP

12:30 – 2:00 PM | Luncheon and Panel Discussion “Getting to Know Your Treasury Tax Experts”
Not Available for CLE/CPE Credit
Moderator: Mandana Parsazad, Vice President, Tax Policy, ACLI
Scott Levine, Acting Deputy Assistant Secretary, (International Tax Affairs), Office of Tax Policy, U.S. Department of the Treasury
Angela Walitt, Attorney Advisor, Office of Tax Policy, U.S. Department of the Treasury

2:00 – 3:00 PM | Concurrent Tracks

4A) P&C Company Tax Discussion
This panel will focus on the federal income taxation issues applicable to P&C insurance companies. Participants will hear specialists’ unique points of view on topics including the recently enacted Corporate Alternative Minimum Tax as it affects nonlife insurers, current trends in the deal market, and common issues faced by tax departments of nonlife insurance companies.  Additionally, panelists will discuss developments surrounding key provisions of Subchapter L along with other recent changes to the law impacting P&C companies.

After completing this course, you will be able to:

  • Identify current operational challenges faced by P&C company tax departments.
  • Analyze current tax law around captive insurance companies.
  • Understand technical tax issues affecting P&C insurance companies.

Moderator: Lori Robbins, Managing Director, KPMG LLP
Mayowa Dauda, Partner, PwC
Scott Rynda, Senior Vice President, Corporate Tax, The Travelers Companies, Inc.

4B) Investment Taxation: Trends
The panel will discuss taxation and process matters related to insurance company investment portfolios. Topics which may be covered include unrealized losses and valuation allowance considerations, hedging, pending investments tax guidance, and the current state of tax systems, data and processes for investments.

After completing this course, you will be able to:

  • Identify high level tax implications and relevant issues for investment portfolio unrealized losses.
  • Understand challenges and solutions related to investments taxation data, process and technology.
  • Recognize changes in investment operating models.

Moderator: David Altschuler, Tax Partner, Deloitte Tax LLP
Albert DiGiacomo, Tax Senior Manager, Deloitte Tax LLP
Bill Elwell, Head of Corporate Tax Law, Massachusetts Mutual Life Insurance Company
Ryan Wilson, Director, PwC

3:10 – 4:10 PM | Concurrent Tracks

5A) OECD Developments Relevant to Multinational Insurance Groups
The panel will discuss Pillar Two developments that are relevant to outbound insurance groups. The panel will provide a global legislative update and an overview of the latest OECD Administrative Guidance. The panel will also discuss the interplay and impact of Pillar Two and Notice 2023-80, the UTPR Safe Harbor, and other various open technical issues. Additionally, the panel will cover the interplay between Pillar Two and other recent legislative developments, including Bermuda Corporate Income Tax, as well as what’s coming next for US MNE Groups as it relates to Pillar Two.

After completing this course, you will be able to:

  • Identify and discuss general trends and developments of Pillar Two across the globe.
  • List key Pillar Two technical issues outbound insurance groups are currently facing.
  • Analyze the interplay between Pillar Two and other recent legislation.

Moderator: Bob Stack, Managing Director, Washington National Tax, Deloitte Tax LLP
Brett Bloom, Attorney Advisor, Office of Tax Policy, U.S. Department of the Treasury
Rebecca Burch, Managing Director, Washington Council Ernst & Young
Shannon Lenihan, Tax Manager, Deloitte Tax LLP
Peter Sproul, Principal, PwC

5B) Health Insurance Tax
The panel will discuss tax and legal issues relating to health insurance companies and healthcare products. Topics to be discussed include treatment of fixed indemnity health coverage, an update on No Surprises Act developments, the Optimal Wireless v. IRS case involving pre-enforcement challenges to section 4980H assessments, tax implications arising from RBC planning, affiliations with tax-exempt entities, tax-exempt status for ACOs, and risk-sharing arrangements with providers.

After completing this course, you will be able to:

  • Understand the current tax treatment of fixed indemnity health coverage.
  • Identify tax issues associated with RBC planning.
  • Understand tax issues that arise in affiliations with tax-exempt entities and other types of provider organizations.

Moderator: Maria Jones, Member, Miller & Chevalier
Rebecca L. Baxter, Senior Technician Reviewer, IRS Office of Chief Counsel (FIP)
Kevin Knopf, IRS Office of Chief Counsel (EEE)
James Kress, Managing Director, PwC
Fred von Rueden, Executive Director, Blue Cross Blue Shield Association

5C) Product Tax Update – SECURE Act and Other Recent Developments
This panel will focus on recent product tax developments, with a particular emphasis on recently issued guidance related to the SECURE 1.0 and 2.0 Acts.  The panel will also discuss other recent developments, including the budget items relating to life insurance and annuities, an update on the section 7702 interest rates, items that were added to the 2023-2024 IRS Priority Guidance Plan, and certain case law developments.

After completing this course, you will be able to:

  • Understand how recent guidance on key Secure 1.0 and 2.0 provisions will affect your organization.
  • Analyze how recent developments in the case law might be relevant to transactions relating to products offered by insurance companies.
  • Evaluate how items on the IRS Priority Guidance plan might affect life insurance companies and the products they issue.

Moderator: Alison Peak, Partner, Davis & Harman LLP
John E. Glover, Senior Counsel, IRS Office of Chief Counsel (FIP)
Kim Lunn, Assistant General Counsel & Assistant Secretary, Northwestern Mutual Life Insurance Company
Tamara Saverine, Vice President, Corporate Counsel, Prudential Financial Inc.
Jeffrey Stabach, Manager, Ernst & Young LLP

4:10 – 4:30 PM | Afternoon Break

4:30 – 5:30 PM | Concurrent Tracks

6A) Information Reporting and Withholding on Insurance Products
This panel will discuss recent IRS guidance and other developments concerning reporting and withholding issues for insurance products. The issues include those raised by (1) recent legislative proposals with respect to private placement insurance products, (2) the proposed regulations under sections 101 and 6050Y, (3) recent developments with respect to Forms W-4P and W-4R (4) information reporting of settlements associated with insurance products and other topics of interest in information reporting and withholding.

After completing this session, you will be able to:

  • Understand and identify information reporting issues associated with proposed changes in federal tax law relating to private placement products.
  • Understand information reporting under proposed regulation with respect to reportable policy sales and section 1035 exchanges.
  • Understand implementation and recent developments with respect to information reporting on Forms W-4P and W-4R.
  • Analyze the information reporting implications associated settlements associated with insurance products.

Moderator: Mary Monahan, Partner, Eversheds Sutherland
Samera Kadry, AVP and Senior Counsel, Lincoln National Life Insurance Company
Ernest Molinari, VP & Corporate Counsel, Prudential Financial Inc.
Kimberly Slagus, Director, Tax Information Reporting & Withholding, PwC

6B) Trending Tax Considerations in the M&A Marketplace
This panel will discuss doing deals in the current fluid tax environment, where major tax changes have become (or soon will become) effective, and implementing guidance is still under development.  During our discussion, we aim to address a number of trending tax considerations in the M&A marketplace, including issues related to the new corporate income tax introduced in Bermuda, Pillar Two, and the corporate AMT.  We also will review recent transactional paradigms and touch on the evolving state of the private letter ruling program at the IRS.

After completing this course, you will be able to:

  • Identify recent trends in the insurance M&A marketplace.
  • Describe key topics of interest when considering the potential impacts of the new corporate income tax introduced in Bermuda, Pillar Two, or the corporate AMT on a contemplated M&A transaction.
  • Discuss potential opportunities for obtaining a private letter ruling from the IRS on a transactional matter.

Moderator: William Pauls, Principal, Washington National Tax, Deloitte Tax LLP
Aditi Banerjee, Vice President, Corporate Counsel, Prudential Financial Inc.
Peter Edgerton, Partner, Sidley Austin LLP
Gregory J. Galvin, Senior Technician Reviewer, IRS Office of Chief Counsel (CORP)
Christine Watson, Partner, PwC

6C) Key Developments in Tax Controversy
This panel will discuss recent critical developments in tax controversy area.  The panel will cover the ramifications of pending cases in the Supreme Court dealing with Chevron deference and the taxation of unrealized gains.  The panel will also discuss cases in the lower courts dealing with Administrative Procedure Act challenges, the application of the economic substance doctrine and penalty administration. Additionally, the panel will provide a discussion of best practices and developments in examination and Appeals.

After completing this course, you will be able to:

  • Understand and explain Chevron deference and the potential implications of the Supreme Court’s pending reconsideration in Loper Bright Enterprises v. Raimondo and Relentless, Inc. v. United States Dept. of Commerce.
  • Understand and explain the implications of the Supreme Court’s pending case in Moore v. United States, considering a constitutional challenge to the taxation of unrealized gains.
  • Understand and explain recent cases dealing with Administrative Procedure Act challenges, the economic substance doctrine and penalties enforcement.
  • Provide an overview of best practices and developments in examination and Appeals.

Moderator: Samuel Mitchell, Partner, Scribner, Hall & Thompson, LLP
Nikole Flax, Principal, PwC
William Olver, Senior Manager, Tax, KPMG LLP
Thomas D. Sykes, Managing Member, Law Offices of Thomas D. Sykes PLLC

5:30 – 7:00 PM | Reception Sponsored by LexisNexis

Friday, May 31 

8:00 – 9:00 AM | Registration + Breakfast

8:30 – 9:10 AM | Chief Counsel:FIP:Insurance Branch Update
Not Available for CLE/CPE Credit
Attorneys from the Insurance Branch of the IRS Office of Chief Counsel’s Financial Institution & Products division will discuss their workload, priorities, processes for various guidance, any recently issued guidance, and the current Priority Guidance Plan items as appropriate. Attendees will be provided the opportunity to ask questions.

Moderator: Jean Baxley, Tax Managing Director, Washington National Tax, Deloitte Tax LLP
Rebecca L. Baxter, Senior Technician Reviewer, IRS Office of Chief Counsel (FIP)
James G. Carpino, General Attorney, IRS Office of Chief Counsel (FIP)
Ian M. Follansbee, General Attorney, IRS Office of Chief Counsel (FIP)
John E. Glover, Senior Counsel, IRS Office of Chief Counsel (FIP)
George F. O’Donnell, General Attorney, IRS Office of Chief Counsel (FIP)
Allan H. Sakaue, General Attorney, IRS Office of Chief Counsel (FIP)
Kathryn M. Sneade, Branch Chief, IRS Office of Chief Counsel (FIP)

9:20 – 10:20 AM | Concurrent Tracks

7A) Multistate Tax Topics of Interest
The panel will explore recent developments impacting the insurance industry resulting from business changes as well as legislative activity. Topics to be addressed include nexus, filing obligations and sourcing of receipts for both direct and indirect tax purposes.

After completing this course, you will be able to:

  • Discuss considerations regarding nexus, apportionment, filing requirements, receipt sourcing and “in-lieu” provisions.
  • Evaluate the impact of Pass-through entity taxes on insurance organizations.
  • Identify key market trends related to indirect taxes, and what challenges are emerging within the market today.

Moderator: Mike Plotkin, Managing Director, PwC
Tim Mahon, Senior Manager, Ernst & Young LLP
Chelsea Marmor, Counsel, Eversheds Sutherland
Charles Treanor, Senior Tax Manager, Deloitte Tax LLP

7B) Select Consolidated Return Topics Relevant to Insurance Groups Including Life/Nonlife and CAMT
This course will include a discussion of insurance company loss utilization in a consolidated return context, life/nonlife group membership (including “tacking rule”) planning, CAMT developments of particular relevance to insurance groups, and application of the “next day rule” to reinsurance and other closing date transactions/payments that occur upon an insurance company joining or leaving a consolidated group.

After completing this course, you will be able to:

  • Evaluate and determine the appropriate utilization of certain insurance tax attributes within a consolidated group.
  • Evaluate application of the “tacking rule” to new captive insurers and other insurance companies formed within an existing consolidated group.
  • Identify and evaluate key CAMT tax planning considerations that impact insurance groups.
  • Evaluate the application of the “next day rule” to reinsurance and other closing date transactions that occur when an entity joins or leaves a consolidated group.

Moderator: Gary Vogel, Tax Managing Director, Ernst & Young LLP
Laura Dinsmore, Tax Director, PwC
Brian Patz, Senior Manager, Deloitte Tax LLP
Daniel Priest, Partner, Debevoise & Plimpton LLP

7C) IRS Practice and Procedure Primer
This primer will discuss a taxpayer’s opportunities to engage with the IRS regarding tax disputes, including before disputes begin. The panel will discuss current areas of IRS enforcement focus, including as a result of the Inflation Reduction Act. We will also explore the lifecycle of a tax dispute with the IRS, best practices for managing an audit, and the possible outcomes that can result. The panel will identify the alternative dispute resolution vehicles available to taxpayers, including the IRS Independent Office of Appeals. For those situations where an administrative resolution is not reached, the panel will also identify possible litigation avenues.

After completing this course, you will be able to:

  • Identify the current areas of key IRS enforcement focus.
  • Understand the lifecycle of an IRS audit and best practices.
  • Understand alternative dispute resolution options available for taxpayers.
  • Understand the options available for settlement with the IRS or, in the alternative, litigation.

Moderator: Jaclyn Roeing, Counsel, Miller & Chevalier
Holly Paz, Commissioner, Large Business & International, IRS 
Rosemary Sereti, Managing Director, Deloitte Tax LLP
Christopher Whitcomb, Managing Director, KPMG LLP

10:20 – 10:40 AM | Morning Break

10:40 – 11:40 AM | Concurrent Tracks

8A) Emerging Accounting Topics
This panel will focus on CAMT, including the intersection of book accounting and tax, Pillar 2 accounting considerations, financial statement considerations relating to the enactment of the Bermuda Corporate Income Tax, recent valuation allowance issues and the recently-released ASU 2023-09, which provides improvements to income tax disclosures.

After completing this course, you will be able to:

  • Understand the tax accounting considerations with respect to Pillar 2, CAMT, and Bermuda CIT.
  • Understand valuation considerations associated with the current market considerations.
  • Identify income tax disclosures that will need to be updated with the adoption of ASU 2023-09.

Moderator: Sarah Pisacich, Partner, KPMG LLP
Arash Barkhordar, Principal, Crowe LLP
Michael Beaty, Partner, Ernst & Young LLP
Aaron Maguire, Vice President-Head of Tax, Jackson National
William Spiller, Tax Law Specialist, IRS Office of Chief Counsel (IT&A)

8B) IRA “Green” Credits and Incentives
The Inflation Reduction Act (IRA) introduced transferable Federal tax credits. Under 6418 certain tax credits can be sold by the party that generated them to an unrelated party for cash. Sale leaseback and complex partnership structures are no longer necessary to monetize tax credits. Insurance companies who are frequent purchasers of state premium tax credits are turning out to be major purchasers of Federal income tax credits as well. The panel will discuss the post-Inflation Reduction Act transferable tax credit landscape including:

  • The rules around transferable tax credits,
  • The transferable credits market
  • Common tax technical and legal issues in transactions,
  • Expectations regarding transferable credit market evolution, and
  • The effects of tax insurance on market efficiency.

After completing this course, you will be able to:

  • Understand and apply the basic rules around tax credit transfers under 6418.
  • Understand why someone would or would not want to buy federal tax credits.
  • Understand different insurance products we see in the transferable tax credit market.

Moderator: Michael Bernier, Partner, Ernst & Young LLP
Robert Kovacev, Member, Miller & Chevalier
Trevor Salzman, Senior Manager, Grant Thornton
Jerry Smith, Managing Director, Head of Tax Insurance, Atlantic Global Risk

>Session Sponsored by Stonehenge Capital 

8C) Ethics of Using Artificial Intelligence in Tax Practice
Artificial intelligence is rapidly transforming tax practice. In late 2022, OpenAI launched ChatGPT, a generative artificial intelligence program that uses chat functionality to answer questions about anything. While generative AI may be able to draft documents ranging from routine correspondence to a complex analysis of recent court opinions, tax practitioners will have to carefully consider how to use this new technology while still upholding their ethical obligations to clients. Generative AI can pose risks implicating practitioners’ duties, including the duties of competence, supervision, and confidentiality. This session will discuss the power of generative AI technology, its potential impact on the world of tax, and the ethical considerations of its use in tax practice.

After attending this course, you will be able to:

  • Identify potential ethical issues of using generative AI as a tax practitioner.
  • Describe how the ABA Model Rules of Professional Conduct and Circular 230 apply to this new technology.
  • Describe what tax practitioners should know as generative AI and applicable rules evolve.

Moderator: Caitlin Tharp, Associate, Steptoe LLP
Travis Thompson, Attorney, Sideman & Bancroft, LLP

11:50 AM – 12:30 PM | 9) “Ask the Experts”
Not Available for CLE/CPE Credit
During this session, we’ll hear from industry tax specialists regarding their top-of-mind tax issues for 2024 and into the future—including the likely impact of recent and future legislation and IRS and Treasury guidance.

Moderator: Mark Smith, Managing Director, PwC
Pamela Biesecker, Senior Vice President, Head of Tax, Nationwide Mutual Insurance Company
Matthew Lodes, Partner, PwC
Chris Ocasal, Principal, Ernst & Young LLP
Peter H. Winslow, Partner, Scribner, Hall & Thompson, LLP